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require more time due to the complexity of this action and the limited amount of case law <br />interpreting the Colorado Surface Coal Mining Reclamation Act, C.R.S. § 34 -33 -101, et seq. <br />3. Per C.R.C.P. 6(b)(1), enlargement of time sought before the expiration of a deadline <br />shall be freely granted for cause shown. A trial court has "broad latitude" in permitting enlargement <br />of time in which to file pleadings. People v. McBeath, 709 P.2d 38, 39 (Colo. App. 1985). <br />4. Plaintiffs' response is due today, April 26, 2011, and therefore this motion is timely. <br />This case is in its infancy, and there will be no prejudice to any party associated with <br />this extension. <br />WHEREFORE, Plaintiffs request an extension of time up to and including May 3, 2011 in <br />which to file their response to Defendant's Motion. <br />Submitted this 26`x' day of April, 2011. <br />DUFFORD, WALDECK, MILBURN & KROHN, L.L.P. <br />[Original signature on file at the offices of Dufford, Waldeck, <br />Milburn & Krohn, LLP] <br />By: /s/ Carin Ramirez <br />Carin Ramirez, #42744 <br />Attorneys for Plaintiffs <br />2 <br />